Harmonized Tariff Schedule

pile of money (dollars) on the table

Exclusions, Free Trade, and Special Tariff Programs: Are You Missing Out?

Most importers treat tariffs as a fixed cost. The rate appears, the broker files, the invoice gets paid, everyone moves on. That approach is understandable. It’s also frequently expensive. A surprising number of companies leave money on the table—not because they’re careless, but because they assume duty exposure is automatic and unavoidable. Like gravity, but […]

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Tariffs on american flag raising concerns about international trade

What Importers Should Watch When Trade Policy Shifts Overnight

Trade policy has always been political. What has changed is the speed. A new executive order. A tariff announcement. A sanctions update. A court decision. A sudden enforcement priority shift. Importers can wake up on Tuesday operating under assumptions that were perfectly reasonable on Monday. The risk is not the rule change itself, but rather

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Blue cargo truck driving through the country

338 And the Vessel Clause: A Tariff You Can Drive Around

In this part two of our three-part article on Section 338, we explore the “imported in a vessel of…” clause. Now that the SCOTUS has struck down the IEEPA tariffs, what can we expect as a reaction from the Administration?  Two words: section 338 (OK, one word and one number.  Sue me.) Section 338 of the Tariff Act of 1930 contains

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CBP’s $1 Billion De Minimis Announcement and the Procedural Refund Problem

Informal Entries, Section 321, and Why “Refunds Later” Is a Procedural Assumption U.S. Customs and Border Protection recently announced that it has collected more than $1 billion in duties following the suspension of duty-free de minimis treatment under Section 321. The announcement highlights the scale and speed with which duties are now being collected on

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Import tariff document stamped in red on desk with pen nearby

The IEEPA Tariff Refund Question No One Is Asking

Informal Entries, Section 321, and a Procedural Gap in the Case Law Recent litigation over tariffs imposed under the International Emergency Economic Powers Act (IEEPA) has focused on a recurring procedural question: if the tariffs are ultimately held unlawful, can importers recover the duties they paid?  In addressing that question, courts have declined to halt

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The U.S. Chocolate Tariff-Rate Quota: A Compliance Perspective (Plus a Debate About Candy)

Trade compliance teaches humility. Sometimes that humility comes from parsing the Uruguay Round; sometimes it comes from your spouse in the candy aisle at H-E-B. Let’s set the stage. As an update to my video on this subject in 2024, CBP’s Quota Bulletin 26-216 2026 for the 2026 quota year reminds us that the United

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Stoic and Zen Thinking for Stronger Trade Compliance

Calm realism, disciplined process, and freedom through precision In trade, as in life, denial is expensive. The Stockdale Paradox teaches that we must confront the brutal facts of our situation while maintaining unwavering faith in our ability to endure and succeed. Stoicism meets Zen here: both demand clear perception without attachment to outcomes. The Stoic

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A customs worker looking at a tablet while reviewing cargo

What CBP Is Looking For in Your Classification Justification (and What Happens If You Don’t Have It)

When Customs and Border Protection (CBP) asks how you arrived at your tariff classification, they are not making polite conversation. They want to know whether your decision was based on a reasoned analysis or a lucky guess. A classification justification is the documented reasoning behind your chosen Harmonized Tariff Schedule (HTS) code. It is one

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